ˆ200FaFsFdno2aJTsuŠ 200FaFsFdno2aJTsu 376784 TX 1 PHILIPS INTERNATIONA SD 25-May-2021 19:44 EST HTM LON Donnelley Financial ADG kumar9an None 3* ESS 0C VDI-W7-PFL-0109 14.4.13.0 Page 1 of 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM SD SPECIALIZED DISCLOSURE REPORT KONINKLIJKE PHILIPS N.V. (Exact name of the Registrant as specified in its charter) ROYAL PHILIPS (Translation of Registrant’s name into English) The Netherlands 001-05146-01 None (State or other jurisdiction of Incorporation or organization) (Commission File Number) (IRS Employer Identification No.) Breitner Center, Amstelplein 2, Amsterdam, The Netherlands 1096 BC (Address of principal executive offices) (Zip code) Sophie Bechu, Chief of Operations +31 20 59 77111, [email protected], Breitner Center Amstelplein 2, 1096 BC Amsterdam, The Netherlands (Name and telephone number, including area code, of the Person to contact in connection with this report.) Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies: ☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
KONINKLIJKE PHILIPS N.V. (Exact name of the Registrant as specified in its charter)
ROYAL PHILIPS (Translation of Registrant’s name into English)
The Netherlands 001-05146-01 None
(State or other jurisdiction of
Incorporation or organization)
(Commission
File Number)
(IRS Employer
Identification No.)
Breitner Center, Amstelplein 2, Amsterdam, The Netherlands 1096 BC
(Address of principal executive offices) (Zip code)
(Name and telephone number, including area code, of the Person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form
applies:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
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Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Koninklijke Philips N.V. evaluated its current product lines and determined that certain products we manufacture or contract to manufacture contain tin,
tungsten, tantalum and/or gold (3TG).
Conflict Minerals Disclosure
Koninklijke Philips N.V. has, in good faith, conducted a reasonable country of origin inquiry (“RCOI”) to determine whether its products contain
conflict minerals originated in the Democratic Republic of the Congo or an adjoining country as described in the Company’s Conflict Minerals Report
provided as Exhibit 1.01 hereto.
We have not been able to confirm the identification of and conflict-free status under the Responsible Minerals Assurance Process (RMAP) standards for
all smelters used in our supply chain. None of the smelters identified in our supply chain is known to us as sourcing 3TG that directly or indirectly
finances or benefits armed groups in the covered countries. As a result we file a Conflict Minerals Report as an Exhibit to this filing.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at:
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly
authorized undersigned.
KONINKLIJKE PHILIPS N.V.
(Registrant)
By: /s/ Sophie Bechu Date: May 27, 2021
Name: Sophie Bechu
Title Chief of Operations
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Exhibit 1.01
Philips Conflict Minerals Report
This Conflict Minerals Report for Koninklijke Philips N.V. (hereafter ‘’Royal Philips’’, “Philips”, or “our”) covers the reporting period from January 1,
2020 to December 31, 2020, and has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934.
This Conflict Minerals Report is filed as Exhibit 1.01 to Philips’ Specialized Disclosure Report on Form SD and is also posted on the Philips conflict
2 The content of any website, including any website of Royal Philips, referred to in this Conflict Minerals Report is included for general
information only and is not incorporated by reference in the Conflict Minerals Report or Form SD.
1
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Contents
1. Introduction 3
2. Philips conflict-free minerals program 3
Philips 3
Supply chain characteristics for 3TG 4
Philips due diligence program 4
OECD Step 1: Company Management system 5
OECD Step 2: Risk identification and assessment 6
OECD Step 3: Strategy to respond to identified risks 7
OECD Step 4: Audits of smelter due diligence practices 7
OECD Step 5: Report annually on supply chain due diligence. 8
3. Reasonable Country of Origin Inquiry results 8
4. Due diligence framework & measures 10
Framework 10
Measures 10
5. Due diligence outcomes 11
6. Determination 12
7. Steps to improve future due diligence 13
8. List of smelter facilities 14
9. Data sources used 28
10. Abbreviations 28
2
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1. Introduction
Rule 13p-1 under the Securities Exchange Act of 1934, as amended, requires a company to make disclosures, for each calendar year, if conflict minerals
are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured. The
specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and
tungsten (henceforth referred to as “3TG”).
Philips has concluded that for the period from January 1, 2020 to December 31, 2020:
• Philips has manufactured and contracted to manufacture products as to which 3TGs are necessary to the functionality or production;
• Based on the reasonable country of origin inquiry (RCOI), Philips knows or has reason to believe that a portion of its necessary 3TGs originated
or may have originated from the Democratic Republic of the Congo (DRC) or an adjoining country and knows or has reason to believe that they
may not be solely from recycled or scrap sources; and
• Based on Philips’ due diligence measures on the source and chain of custody of those necessary 3TGs used in its products, Philips is unable to
determine for all 3TGs used in its products whether they originated from the DRC or an adjoining country.
2. Philips conflict minerals program
Philips
Royal Philips (NYSE: PHG, AEX: PHIA) is a leading health technology company focused on improving people’s health and well-being, and enabling
better outcomes across the health continuum – from healthy living and prevention, to diagnosis, treatment and home care. Philips leverages advanced
technology and deep clinical and consumer insights to deliver integrated solutions. The company is a leader in diagnostic imaging, image-guided
therapy, patient monitoring and health informatics, as well as in consumer health and home care.
In 2020, Royal Philips was organized around the following reportable segments:
• Connected Care businesses: Monitoring & Analytics, Sleep & Respiratory Care, Therapeutic Care, Population Health Management,
Connected Care Informatics
• Personal Health businesses: Oral Healthcare, Mother & Child Care, Personal Care, Domestic Appliances
• Other: Innovation, IP Royalties, Central Costs, Other
On March, 25, 2021 Philips announced that it has signed an agreement to sell its Domestic Appliances business, a global leader with EUR 2.2 billion
sales in 2020 in kitchen, coffee, garment care and home care appliances, to Hillhouse Capital, a global investment firm focused on helping companies
achieve long-term sustainable growth through digital innovation and enablement. The transaction is expected to be completed in the third quarter of
2021, subject to customary closing conditions, including the relevant regulatory approvals.
3
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Supply chain characteristics for 3TG
The supply chain for 3TGs consists of many tiers. Before reaching Philips’ direct suppliers, in general, 3TGs will go from mines to traders, exporters,
smelters or refiners (collectively referred to in this report as smelters), alloy producers and component manufacturers, and sometimes intermediate
suppliers. One or more of the 3TG metals are contained in the vast majority of Philips products, typically in small quantities. Philips sources products
and components from approximately 3,300 first tier suppliers globally. First tier suppliers are those suppliers that Philips selected and with whom
Philips has a direct business relationship. These first tier suppliers may select their suppliers (second tier suppliers), which in turn may have their own
group of suppliers (third tier), and so on. There may be seven or more tiers in the supply chain between a 3TG mine and Philips. Philips works with its
first tier suppliers to investigate the deeper levels of the supply chain, to determine the origin of 3TGs contained in Philips products.
Philips conflict minerals due diligence program
Due to Philips’ position in the supply chain and its limited insight in and leverage over the lower levels of the supply chain, Philips engages and actively
cooperates with other industry members. As encouraged in the third edition of the Organization for Economic Co-operation and Development Due
Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (including its supplements on 3TG, referred
to in this report as “OECD Guidance”), the internationally recognized standard on which Philips’ system is based, Philips supports an industry
initiative, the Responsible Minerals Initiative (RMI), that uses an independent third-party audit to identify smelters that have systems in place to assure
sourcing of only conflict-free materials. The RMI, formerly known as the Conflict Free Sourcing Initiative (CFSI), was founded by members of the
Responsible Business Alliance (RBA), formerly known as the Electronic Industry Citizenship Coalition (EICC), and the Global e-Sustainability Initiative
(GeSI).
The data on which certain statements in this report are based were obtained through Philips’ membership in the RMI, using the RMI Reasonable
Country of Origin Inquiry report3. In addition, Philips uses the tools and supports the initiatives developed by the RMI especially the Conflict Minerals
Reporting Template (CMRT) and Responsible Minerals Assurance Process (RMAP), formerly known as the Conflict Free Smelter Program (CFSP).
3 This list provides country of origin information for smelting and refining facilities that are validated through the Responsible Minerals Assurance
Process. This data is based on the results of independent third-party audits and is available to RMI member companies only. The audit standard is
developed according to global standards including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-
Affected and High-Risk Areas and the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act.
4
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Philips designed its conflict minerals supply chain due diligence program with reference to the OECD Guidance and the five steps described in the
supplements on 3TG.
OECD Step 1: Company Management system
Philips adopted a position paper on responsible sourcing in relation to conflict minerals. The position paper is posted on Philips’ website. In addition,
Philips has communicated its position on conflict minerals to all priority suppliers (see below section “OECD Step 2” for the definition of priority
suppliers). Philips has committed not to purchase raw materials, subassemblies, or supplies, which Philips knows contain conflict minerals that directly
or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC), an adjoining country or any conflict-affected or high-risk
areas (CAHRAs). Philips’ program goals, as described in the position paper, encourage the development of initiatives to:
• Stop the trade in conflict minerals from mines that directly or indirectly finance or benefit armed groups anywhere in the world.
• Enable responsible sourcing of minerals from conflict-affected and high-risk regions, thereby supporting the development of the local
economy and communities.
Philips created and maintains an internal conflict minerals team to manage the implementation and progress of Philips’ due diligence efforts. The
internal team consists of representatives from Procurement, Sustainability, Finance, Export Control, Legal and the Secretariat of the General Business
Principles (GBP) Review Committee.
Philips established a system of control and transparency over its 3TG supply chains by creating a process to engage a group of first tier priority suppliers
and request them to submit information to Philips using the CMRT4. The information submitted by priority suppliers includes information gathered by
those suppliers about the smelters identified in their own supply chains. The information has been used by Philips to assess the due diligence efforts
implemented by priority suppliers, and to identify smelters in the supply chain.
Philips made responsible sourcing of minerals a supplier contract requirement. The Philips Supplier Sustainability Declaration5 (SSD) includes a
provision about Responsible Sourcing of Minerals. The SSD is part of the general conditions of purchase, and of the purchasing agreements signed with
suppliers. It requires suppliers to have a policy in place to reasonably assure that their 3TG does not directly or indirectly finance or benefit armed
groups that are perpetrators of serious human rights abuses in the DRC, an adjoining country or CAHRAs, and to exercise due diligence on the source
and chain of custody.
For first tier suppliers, Philips has a supplier sustainability performance program6 in place in which, amongst others, the implementation of the SSD is
assessed. Responsible Sourcing of Minerals is one of the topics reviewed in this program. In case non-conformances are identified during the
assessment, suppliers are requested to make a corrective action plan and Philips monitors the implementation of this plan until the non-conformance is
corrected.
4 The CMRT is a survey tool developed by the RMI to standardize collection of due diligence information in the supply chain.
5 More information on the Supplier Sustainability Declaration can be found here:
Multiple communication channels exist to serve as grievance mechanisms for early-warning risk awareness. Philips has the Philips SpeakUp policy and
underlying Speak Up mechanism that enables its stakeholders (including employees, former employees and third parties) to inform Philips of any
concerns they may have. Internally, its personnel can report (anonymously) possible violations of Philips GBP7 and other policies including those
related to 3TG supply chains via the GBP Compliance Officer or Philips Speak Up (Ethics Line) using the hotline or a web intake form. Third parties
can also use the Philips Speak Up (Ethics Line) to file a complaint via telephone or a web intake form.8 In addition, stakeholders can use the email
address [email protected] or existing industry grievance mechanisms like RMI and ITRI’s Tin Supply Chain Initiative (iTSCi) to
file complaints related to 3TG.
OECD Step 2: Risk identification and assessment
Given the large number and diversity of Philips’ suppliers, Philips focuses its efforts on a group of first tier priority suppliers (referred to as “priority
suppliers”) and works with them to identify the smelters in their supply chain. Priority suppliers are selected based on two primary elements:
• Purchasing spend
The suppliers in the top 80% of Philips’ spend of relevant commodities are selected as priority suppliers. Philips uses a system to classify
suppliers in commodity groups, for example, plastics, packaging, and metals. Philips excluded suppliers in commodity groups for which it
is unlikely that one or more of the 3TGs are contained in the products, for example, software suppliers and packaging suppliers.
• Usage of 3TG
The suppliers which provide a high quantity of 3TG materials are selected as priority suppliers. Even if these suppliers are not part of the
top 80% relevant purchasing spend, Philips includes the suppliers as they are supplying a relatively high quantity of 3TG materials.
All identified priority suppliers receive a letter formally requesting them to:
• Adopt a policy to reasonably assure that the 3TG in their products does not directly or indirectly finance or benefit armed groups in the
DRC, an adjoining country, or any conflict-affected or high-risk areas (CAHRAs).
• Identify all 3TG smelters in their supply chain. If they do not source directly from smelters, they are asked to pass on this request to their
suppliers (who may have to pass it on to their suppliers, until the smelters are identified).
• Cascade Philips’ request to only source from RMAP (or equivalent) compliant smelters to their suppliers and ask them to do the same with
their next tier partners.
• Report back to Philips by filling in the CMRT.
A Philips conflict minerals team is available to increase awareness amongst priority suppliers and to help them meet Philips’ expectations/requirements.
Different background and training materials are made available to suppliers.
7 More information about the Philips General Business Principles can be found here:
8 More information can be found here: https://secure.ethicspoint.eu/domain/media/en/gui/100518/index.html
6
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Philips reviews each received supplier CMRT and assesses whether it meets Philips’ acceptance criteria regarding completeness, adoption of a conflict-
free policy, data collection from next tier suppliers, and smelter identification and disclosure. Suppliers who provided a CMRT that did not meet the
acceptance criteria, and suppliers who provided incomplete or potentially inaccurate information, were requested to take corrective actions and update
their CMRT accordingly.
Philips reviews the supplier CMRTs to determine if there are any findings that indicate a need to conduct further due diligence and gather more detailed
information.
Philips evaluates the smelters identified in the supplier CMRTs based on various sources of available information. Philips mainly uses the Responsible
Minerals Assurance Process (RMAP) compliant and active9 smelter list to evaluate the identified smelters. RMAP recognizes and includes smelters
from other lists such as the London Bullion Metal Association (LBMA) and Responsible Jewelry Council (RJC). Philips may also use other sources of
information to assess potential risk. In addition, Philips uses numerous factors to determine the level of risk that each smelter poses to the supply chain
by identifying red flags. These factors include geographic proximity to the DRC, Covered Countries, or an embargoed country/region; Known mineral
source country of origin; RMAP audit status; Credible evidence of unethical or conflict sourcing; and Peer Assessments conducted by credible third-
party sources, including international organizations.
OECD Step 3: Strategy to respond to identified risks
Progress and findings of the supply chain risk assessment are regularly reported to senior management. The risk management plan adopted by Philips is
in accordance with its policy to ultimately discontinue doing business with any supplier found to be purchasing 3TG material which directly or
indirectly finances or benefits armed groups in the DRC, adjoining countries, or CAHRAs, after attempts at corrective actions are not successful.
To monitor and track performance of risk management efforts, Philips uses data reported by suppliers in the CMRTs and updates of the RMAP
compliant smelter list. The status is discussed internally in monthly reviews with the conflict minerals team and reported to senior management.
Philips requests priority suppliers to update and resend their CMRT when additional information becomes available to such suppliers. When updates are
received, the CMRT review step as described above is repeated to assess and mitigate risks.
OECD Step 4: Audits of smelter due diligence practices
The fourth step in the OECD guidance is to carry out independent third-party audits of supply chain due diligence at identified points in the supply
chain. Philips is a member of RMI and uses information provided by the RMI for this step. Through its membership, Philips has access to the RMI
RCOI report data which is used to identify the minerals country of origin and conflict-free status of smelters.
Philips contributes to the RMI as a member company and encourages smelters to participate in the RMAP through direct communication and smelter
outreach communication.
9 RMI active smelter and refiners are at various stages of the audit cycle (undergoing or committed to undergo the audit). The full definition of RMI
“active” smelters can be found here: http://www.responsiblemineralsinitiative.org/active-smelters-refiners/
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OECD Step 5: Report annually on supply chain due diligence.
Since 2014, Philips reports annually on supply chain due diligence by filing a Form SD and Conflict Minerals Report with the SEC. Philips has been
including certain disclosures about the use of conflict minerals since 2009, even before the SEC’s rules first became effective. A dedicated conflict
minerals website with information for consumers, customers and suppliers is available. In 2012, Philips was the first company to publish its smelter list,
and continues to regularly update this list as more information becomes available.
3. Reasonable country of origin inquiry results
As described above, SEC rules provide that if, after conducting in good faith, a reasonable country of origin inquiry, an SEC registrant determines, or
has reason to believe, that any of the 3TGs used in connection with the products for which it is responsible may have originated in the DRC or an
adjoining country, or did not come from recycled or scrap sources, the registrant should conduct due diligence on the source and chain of custody of its
conflict minerals, following a nationally or internationally recognized framework.
Philips identified 196 priority suppliers and used the data provided by these suppliers in their CMRTs to identify the smelters in the Philips supply
chain. These smelters may have been used to process 3TG metals contained in Philips products.
Philips achieved a 99% response rate in its supply chain investigation and 85% of the submitted CMRTs met or exceeded the Philips 2020 minimum
acceptance criteria. Names of 338 different entities were provided by priority suppliers as part of their smelter lists.
However, some of the entities named by the priority suppliers may not be smelters. Philips used the “Smelter Look-up” in the CMRT version 6.1 and
RMI smelter database information as a reference to compile the Philips Smelter List.
Based on the CMRT “Smelter Look-up”, Philips identified a total of 324 listed smelters in the supply chain out of the 338 names reported to Philips.
According to the RMI smelter database information, among the 324 listed smelters, 2 have discontinued operations as smelters.
Philips researched the remaining 14 non-listed entities and concluded that 10 of them is most likely a smelter that has ceased operations and the other 3
have been recognized in the RMI smelter database after the release of CMRT version 6.1. Therefore, in 2020, Philips identified 325 eligible smelters,
excluding the smelters that have discontinued operations, and did not identify any named entities that we could not determine the status of.
As a result of focusing on improving the smelter data quality received from the priority suppliers, Philips was able to reduce the number of
non-recognized smelters from 85 reported in 2015, to 9 reported in 2016, to 5 reported in 2017, to 3 reported in 2018, and finally to 0 in 2019 and 2020.
The majority of the identified smelters are located in Asia, with 80 smelters in China, followed by Japan (31) and United States of America (26).
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Results of the RCOI (Reasonable Country of Origin Inquiry)
Gold Tantalum Tin Tungsten Total
Smelters known to source from the DRC 0 24 7 5 36
Smelters known to source from the DRC adjoining countries 2 2 1 5 10
Smelters known to source from CAHRAs 3 26 8 10 47
Smelters known to process only recycled or scrap materials 11 3 4 3 21
Smelters known to source from outside the DRC or adjoining countries 105 11 44 27 187
Smelters that disclosed mineral country of origin to auditors only 74 0 0 14 88
Smelters with unknown mineral origin 58 0 25 9 92
For the 325 identified smelters, Philips used the RMI Reasonable Country of Origin Inquiry (RCOI) report. This country of origin data is available for
smelters that successfully completed an RMAP audit and chose to disclose their sourcing countries to the RMI. One of the identified RMAP compliant
gold smelters chose to disclose its mineral country of origin to auditors only. The table above shows the results of the RCOI. The total number shown in
the table is not equal to the total number of identified smelters, because a smelter may fall into more than one category (e.g., a smelter can source from
both the DRC as well as from countries outside the DRC). As the RMI generally does not specify individual countries of origin of 3TGs processed by
audited smelters and some of the smelters do not disclose origin information, we were not able to determine with certainty the specific countries of
origin of 3TGs processed by the identified smelters.
In the CMRTs received, 47 suppliers indicated that their products contain 3TG metals that originated or potentially originated from the DRC, adjoining
countries or CAHRAs. We then performed due diligence on the source and chain of custody of the conflict minerals in question.
9
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4. Conflict minerals due diligence framework & measures
Framework
The Philips conflict minerals due diligence framework for the reporting period of calendar year 2020 has been designed to conform in all material
respects to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition
(2016), as applicable for downstream companies.
Measures
Below is a description of the measures Philips performed in due diligence on the source and chain of custody of the necessary conflict minerals
contained in Philips’ products.
• Philips updated its position paper on responsible sourcing in relation to conflict minerals.
• Once a month, the Philips conflict minerals team met to review progress and results of supplier data collection, supplier due diligence and
smelter identification. Internal performance reports were created for these meetings. Using data from Supplier Sustainability Scorecards,
these reports included an overview of the monthly progress of priority suppliers, as well as, progress highlights, areas of concern, outlook
for coming weeks, and identified risks.
• In total, 12 Supplier Sustainability Scorecards were shared with senior management. Regarding Conflict Minerals, the main topics
addressed in the scorecards included:
• The progress of CMRT collection from priority suppliers
• The status of supplier CMRTs with regards to meeting Philips’ CMRT acceptance criteria
• Philips contacted priority suppliers via an invitation letter. Using this letter, Philips requested suppliers to perform supply chain due
diligence and fill out a CMRT. In addition, the letter referred to Philips’ expectations and requirements regarding the CMRT. A copy of
this letter is posted on the Philips conflict minerals website.
• In the letter, Philips requests priority suppliers to steer their supply chain towards RMAP (or equivalent) validated smelters only.
• Philips requested priority suppliers to identify smelters in their supply chain and to report the identified smelters to Philips using the
CMRT. In case a lack of progress was observed, Philips followed up with suppliers by sending out multiple reminders via email, as well
as, by reaching out via phone.
• Philips facilitated the learning and development of suppliers. The Philips Conflict Minerals team regularly contacted suppliers via email
and phone to monitor the suppliers’ progress, provide additional training, and check whether the conflict minerals requirements of Philips
were interpreted correctly.
• Philips reviewed all received supplier CMRTs to evaluate whether they met Philips’ acceptance criteria regarding completeness, adoption
of a conflict-free policy, data collection from next tier suppliers, and smelter identification and disclosure. Suppliers that provided a
CMRT that did not meet the acceptance criteria, and suppliers that provided incomplete or potentially inaccurate information, were
requested to take corrective actions and update their CMRT accordingly.
10
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• Philips reviewed all received supplier CMRTs to determine if there were any areas of concern giving rise to the need to conduct further
due diligence and thus gather more information. During the course of the year, Philips has followed up on areas of concern in a number of
cases.
• Philips reviewed all received supplier CMRTs against the list of smelters that were audited through the RMI’s Responsible Minerals
Assurance Process (RMAP) or other independent third party audit programs.
• As a member of the RMI, Philips utilized the due diligence conducted on smelters by the RMI’s RMAP. This program uses independent
third-party auditors to audit the source and chain of custody of the conflict minerals used by smelters that agree to participate in the
RMAP.
• Philips devised and adopted a risk management plan according to the level of risk in 3TG supply chains. Philips determined the level of
risk, taking into account available information on mineral origin, RMAP compliance status, and possible connection to conflict as reported
from credible sources. To mitigate risk, Philips might require high-risk suppliers to take corrective actions, or request smelters with
unknown mineral origin to participate in the RMAP.
• Philips published the “Philips Conflict Minerals Reporting Template” on the Philips conflict minerals website, including a list of smelters
identified by the selected priority suppliers during 2020.
• Philips has filed the Conflict Minerals Report (and the Exhibits thereto) with the SEC for 2013, 2014, 2015, 2016, 2017, 2018, and 2019
and is filing this the Conflict Minerals Report for 2020 on May 27, 2020 as Exhibit 1.01 to Form SD. The report is available on Philips’
conflict minerals website.
• Philips archives relevant evidence related to its Conflict Minerals Program for at least five years. Records are stored in a manner allowing
timely and easy access while protecting the records from unauthorized alteration.
• Philips has established an internal mechanism allowing its employees to, anonymously, raise possible violations of Philips GBP and other
policies including those relating to conflict minerals. In addition, a central conflict minerals email address can be used by external
stakeholders to file complaints. Additionally, Philips encourages anyone who suspects a breach of ethical standards in any of Philips’
business activities to report their concerns, in strictest confidence, via the externally hosted Philips Speak Up (Ethics Line). Moreover, as a
member of the RMI, Philips encourages submissions of grievance via the RMI Grievance Mechanism. The RMI also serves as a source for
an early-warning risk-awareness.
5. Conflict minerals due diligence outcomes
To the best of Philips’ knowledge, none of the smelters identified in Philips’ supply chain are known to source 3TG that directly or indirectly benefit
armed groups in the DRC. 264 (81%) of the 325 smelters identified by Philips participated in the RMAP or equivalent audit program. 236 (73%) of the
identified smelters successfully passed the RMAP or equivalent audit, thereby confirming their conflict-free status under those standards. 21 (6%) of the
identified smelters are in various stages of the audit (so-called “RMI active smelters”). The remaining 61 (19%) identified smelters have not started a
valid independent third-party audit to confirm their conflict-free status. Accordingly, the conflict-free status of these 61 unaudited smelters as well as the
21 active smelters that are in various stages of the audit process is reported in this conflict minerals report as undeterminable.
Philips did not discontinue business with any direct suppliers in the reporting period because Philips did not identify any reason to believe that any of
the suppliers were purchasing 3TG that directly or indirectly finances or benefits armed groups in the DRC or adjoining countries nor has any supplier
refused to continue investigating and potentially eliminate a red flag smelter from the supply chain, if confirmed. Philips
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nevertheless will review and potentially remove smelters from its supply chain when Philips has concerns regarding their due diligence process and/or
sourcing practices. Given the fact that neither Philips nor its suppliers have a direct business relationship with the entities with respect to which Philips
is further investigating concerns, the process takes time.
6. Determination
Philips has not been able to confirm the identification of a conflict-free status under the RMAP standards for all smelters used in its supply chain.
However, none of the smelters identified in Philips’ supply chain is known to Philips as sourcing 3TG that directly or indirectly finances or benefits
armed groups in the DRC or adjoining countries.
As a result of the due diligence measures performed, Philips provides below the known smelter facilities that may have been used to process 3TG metals
contained in Philips products, and their conflict-free status. The conflict-free status is based on information the RMI provides to its members. Philips
includes the category “RMI Active” as it shows smelters that committed to or are currently in the process of undertaking an audit. The list of smelter
facilities provided in Section 8 of this Conflict Minerals Report includes all 325 entities that were confirmed to be eligible smelters.
This Conflict Minerals Report is intended to cover Philips’ entire product portfolio that uses 3TG. Given Philips’ large product portfolio and extensive
supplier base, Philips does not have component level information from all of its 3,300 first tier suppliers. This means our list of processing smelters and
refiners disclosed in Section 8 may contain more facilities than those that actually processed the conflict minerals contained in our products. As a result
thereof, the approach is to conduct supply chain due diligence and report at the company level for the entire product portfolio, rather than for specific
Philips products. This enables Philips to focus its efforts on building, maintaining, and improving a robust due diligence program.
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7. Steps to improve future Philips conflict minerals due diligence program
For reporting year 2021, Philips plans to:
• Continue to leverage its position as a strategic partner in the European Partnership for Responsible Minerals (EPRM), a public-private
cooperation that supports and complements the EU conflict minerals legislation. As a strategic partner, Philips will engage in responsible
sourcing projects (with a scope broadened to other conflict and high-risk areas world-wide as well as a wider array of human rights and
environmental issues addressed) in order to increase the supply and demand for responsibly sourced minerals. Furthermore, Philips will
act as a liaison between EPRM and other responsible sourcing initiatives in which Philips participates (e.g. the Dutch Covenant on Gold).
• Continue engagement with existing industry programs and groups, such as responsible sourcing and upstream impact programs and
workgroups initiated under the Responsible Minerals Initiative (RMI), to encourage further adoption, improvement, and reliability in
relevant programs, tools and standards.
• Continue to reach out to smelters to encourage their participation in relevant responsible sourcing initiatives.
• Continue to work with priority suppliers to:
• help them understand and satisfy Philips’ responsible sourcing expectations
• help them implement or further improve their due diligence process
• investigate their supply chain and identify smelters
• confirm the conflict-free status of identified smelters
• Continue to communicate to priority suppliers Philips’ expectation that they steer their supply chain towards smelters audited as
conformant to the Responsible Minerals Assurance Process (RMAP) or other equivalent programs.
• Continue exploring its supply chain for cobalt and perform due diligence to include cobalt, which is not included in the definition of
“conflict minerals” but has been linked to human rights risks in the DRC. In 2020, we reached a 100% response rate from cobalt suppliers.
In addition, we performed outreach to cobalt smelters on several occasions.
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8. List of smelter facilities
The table below represents a consolidated list of smelters (325 in total) identified by Philips’ priority suppliers. The results are based on:
• Information provided by the selected priority suppliers in their CMRTs
• RMI smelter reference list, as included in the CMRT version 6.1 (released April 28, 2021)
• Smelter database information available to the RMI members – version May 4, 2021
Metal Smelter ID Standard Smelter Name
RMAP
Compliant
RMI
Active
Gold CID000015 Advanced Chemical Company Yes No
Gold CID000019 Aida Chemical Industries Co., Ltd. Yes No
Gold CID000035 Allgemeine Gold-und Silberscheideanstalt A.G. Yes No
Gold CID000041 Almalyk Mining and Metallurgical Complex (AMMC) Yes No
Gold CID000058 AngloGold Ashanti Corrego do Sitio Mineracao Yes No
Gold CID000077 Argor-Heraeus S.A. Yes No
Gold CID000082 Asahi Pretec Corp. Yes No
Gold CID000090 Asaka Riken Co., Ltd. Yes No
Gold CID000103 Atasay Kuyumculuk Sanayi Ve Ticaret A.S. No No
Gold CID000113 Aurubis AG Yes No
Gold CID000128 Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Yes No
Gold CID000157 Boliden AB Yes No
Gold CID000176 C. Hafner GmbH + Co. KG Yes No
Gold CID000180 Caridad No No
Gold CID000185 CCR Refinery—Glencore Canada Corporation Yes No
Gold CID000189 Cendres + Metaux S.A. Yes No
Gold CID000197 Yunnan Copper Industry Co., Ltd. No No
Gold CID000233 Chimet S.p.A. Yes No
Gold CID000264 Chugai Mining Yes No
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Gold CID000343 Daye Non-Ferrous Metals Mining Ltd. No No
Gold CID000359 DSC (Do Sung Corporation) Yes No
Gold CID000362 DODUCO Contacts and Refining GmbH Yes No
Gold CID000401 Dowa Yes No
Gold CID000425 Eco-System Recycling Co., Ltd. East Plant Yes No
Gold CID000493 JSC Novosibirsk Refinery Yes No
Gold CID000522 Refinery of Seemine Gold Co., Ltd. No No
Gold CID000651 Guoda Safina High-Tech Environmental Refinery Co., Ltd. No No
Gold CID000671 Hangzhou Fuchunjiang Smelting Co., Ltd. No No
Gold CID000689 LT Metal Ltd. Yes No
Gold CID000694 Heimerle + Meule GmbH Yes No
Gold CID000707 Heraeus Metals Hong Kong Ltd. Yes No
Gold CID000711 Heraeus Germany GmbH Co. KG No Yes
Gold CID000767 Hunan Chenzhou Mining Co., Ltd. No No
Gold CID000773 Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. No No
Gold CID000778 HwaSeong CJ CO., LTD. No No
Gold CID000801 Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. Yes No
Gold CID000807 Ishifuku Metal Industry Co., Ltd. Yes No